BBA Partnership Audits:

A Practitioner’s Guide to

Rules, Risk, and Strategy

The Bipartisan Budget Act centralized partnership audit regime fundamentally changed how the IRS examines partnerships and assesses partnership-related adjustments. This two-hour IRS CE, CPA CPE, and North Carolina CLE course gives tax professionals a practical overview of partnership-representative authority, election-out requirements, imputed underpayment calculations, modification procedures, administrative adjustment requests, push-out elections, filing deadlines, notices, and litigation risks.

The Bipartisan Budget Act (“BBA”) was signed into law on November 2, 2015, replacing the partnership audit procedures for partnerships under the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) for tax years generally beginning in 2018.  BBA represents a major change in the way adjustments are made to partnerships and how partnerships make changes to their prior year returns.  Although the BBA is now over 10 years old, it is still relatively new when it comes to audits, cases, and overall procedures. BBA audits have been on the rise with revenue agents and tax professionals working together to navigate filing and notice requirements, imputed underpayment computations and adjustments, push out elections, and litigation of BBA matters in court. 

Taught by Jenni Black, a national tax-procedure and controversy leader who regularly represents partnerships navigating the BBA audit regime. This course will provide an overview of the complex rules contained in the centralized partnership audit regime and provide practitioners with the information they need to know to accurately spot issues and advise their clients for both filing and in the event of a BBA audit.

After completing this course, participants should be able to:

  • Identify and define key terminology associated with the Bipartisan Budget Act (BBA) centralized partnership audit regime

  • Describe the structure and procedural flow of a BBA partnership examination

  • Evaluate partnership-related activities to identify situations were the BBA centralized audit regime may affect the procedural handling of adjustments

  • Explain the purpose, requirements, and timing of an Administrative Adjustment Request (AAR)

Who should Attend:

This course is designed for CPAs, enrolled agents, tax attorneys, partnership return preparers, partnership representatives, controllers, and other professionals who advise partnerships or their partners regarding return filing, administrative adjustments, IRS examinations, imputed underpayments, or tax controversy.

2 IRS CE Hours

Prerequisites: None

Program Level: Basic

Advanced Preparation: None

Field of Study: Taxes

Location: Virtual

Delivery Method: Self-Study

Your Instructor

Jenni Black

Tax Attorney | Former IRS Office of Chief Counsel

Jenni Black is a managing director and head of the Tax Procedure and Controversy practice in Citrin Cooperman Advisors, LLC’s National Tax Office where she assists clients in successfully navigating their interactions with the IRS, especially interactions involving the BBA partnership audit regime. Prior to joining Citrin Cooperman, Jenni was a senior counsel at the IRS Office of Chief Counsel in the Procedure and Administration division of the National Office where she was a subject matter expert and a primary author of the regulations implementing the BBA.

All Self Study must be completed by 12/31/2026 to receive IRS CE Credit

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Office
Boon Tax Educators
Jamestown, NC
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